I see no reason why they couldn't do a 99214 as incident to. You have an established patient with 3 chronic conditions and Rx management, no reason that couldn't be billed incident to if the treatment was established by the doctor.
I am having a hard time seeing how you could get a 99215 incident to. I know established are 2 of 3, and NP are usually really good at getting a lot of history documented and doing very extensive exams. So comprehensive history and exams are not uncommon, in my experience with NPPs. The problem would be the medical necessity piece.
On the flip side if it was met using MDM, my thinking is high complexity is probably going to be a new problem and not meet the incident to requirements.
To my knowledge there is nothing that states NPs can't bill those codes incident to. They will just direct you to what the state allows and the incident to requirements.
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